UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

DEC .2 0 2013 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

BEAD Responses to the Comments on the Simazine BEAD Chemical Profile 

(080807) (EPA-HQ-OPP-2013-0251-0005) and Preliminary Work Plan (EPAHQ-OPP-2013-0251-0008) 

Bill Phillips, PhD, Agronomist ~ Biological Analysis Branch ,)'?'~' 

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Science 

Alsadek, 

Information 

PhD, 

and 

Economist 

Analysis 

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Stephen Smearman, Economist 

Economic Analysis Branch 

Biological and Economic Analysis Division (7503P) 

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Biological 

Jones, 

Analysis 

Chief 

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Diann Sims, Chief 

Science Information and Analysis Branch 

Timothy Kiely, Chief rl\._ ~ Economic Analysis Branch ~ J \A..A._ 

Biological and Economic Analysis Division 03P) 

TO: Molly Clayton, Chemical Review Manager 

Risk Management and Implementation Branch 3 

Pesticide Re-evaluation Division (7508P) 

Product Review Panel date: December 17,2013 

The Environmental Protection Agency (Agency) is implementing the registration review 

program pursuant to Section 3(g) of the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA), and will review each registered pesticide every 15 years to determine whether it 

continues to meet the FIFRA standard for registration. Changes in science, public policy, and 

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pesticide use practices occur over time. The registration review program is intended to make sure 

that, as the ability to assess risk evolves and as policies and practices change, all registered 

pesticides continue to meet the statutory standard. The public phase of registration review begins 

when the initial docket is opened for each case. Information on this program is provided on the 

Agency's website. (EPA 2012) 

Registration review may consist of a review of available information on a pesticide, risk 

assessments, and, potentially, risk management. The Biologic and Economic Analysis 

Division's (BEAD) role is to provide relevant use and usage information for risk assessments 

and to conduct benefit/impact assessments to inform risk management. In the case of 

agricultural uses, these impacts could include changes in yield, in the quality of produce, and/or 

the cost of producing the commodity that affect producers' income and, potentially, could affect 

consumers through the supply and price of commodities. 

On June 26, 2013 the federal docket (HQ-OPP-2013-0251) for the registration review of the 

active ingredient simazine was opened to the public to receive comments regarding the 

preliminary work plan and supporting science documents. The 60 day public comment period 

ended on August 26, 2013. This comment period provided the public the opportunity to submit 

comments about the work that had been undertaken up to the June docket opening. The 

Environmental Protection Agency received comments from various groups and individuals. 

Syngenta Crop Protection, LLC provided the only comments focused on the BEAD chemical 

profile document (EPA-HQ-OPP-2013-0251-0005). Below BEAD has provided responses to the 

comments that were submitted to the simazine docket. 

EPA thanks the public for comments provided to the simazine docket during the public comment 

period. Information provided to the docket and any additional information submitted by the 

public regarding the agronomic, weed science and/or economic relevance of atrazine could be 

useful in future alternatives and/or benefits analysis. 

I. Comments and Responses on the BEAD Chemical Profile for Registration Review: 

Simazine (080807) (EPA-HQ-OPP-2013-0251-0005) 

Comment 1. 

EPA Statement 

Page 2, Herbicide Discussion, 

" .. Simazine can be used postemergence to the weed .... " 

Syngenta Comment: 

Syngenta respectfully requests to delete "post-emergence" from the sentence. 

BEAD Response: In the BEAD chemical profile it states that "Simazine can be used 

postemergence to the weed as a foliar applied herbicide, however since it is readily absorbed 

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through the root system, it is primarily applied as a pre-plant incorporated or soil applied 

herbicide. The characterization of simazine application timing was incorrect in that applications 

that are made postemergence should be made postemergence to the crop, after the crop has 

emerged, but before there are weeds present. 

Comment2. 

EPA Statement 

Page 3, Common Formulations and Application Methods 

" .. Simazine is formulated either as a liquid, emulsifiable concentrate .... " 

Syngenta Comment: Syngenta respectfully requests to delete emulsifiable concentrate as a type 

of formulation. 

BEAD Response: We agree that Syngenta simazine products are not formulated as emulsifiable 

concentrates. Other registrants have simazine products that are formulated as emulsifiable 

concentrates. 

II. Comments and Responses on the Simazine Preliminary Work Plan (EPA-HQ-OPP2013-0251-0008) 

Comment 1. 

EPA Statement 

Page 5, Table 3. 

Summary ofUse 

" .. Simazine can be applied postemergence to the weed .... " 

Syngenta Comment: 

Syngenta respectfully requests to delete "post-emergence" from the sentence. 

BEAD Response: Refer to BEAD's response in Section I, Comment I. 

Comment2. 

EPA Statement 

Page 6, Table 3, 

Use Sites 

" ... Registered for use on crops including ... Brussels sprouts, cranberry, persimmon," 

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Syngenta Comment: Syngenta does not support use on cranberry, please (sic) delete from the 

list. 

Persimmon is also not supported, as the Special Local Needs label (SLN) has been cancelled. 

BEAD Response: BEAD agrees that there are no Simazine registrations supporting use on 

persimmons. However, while there are no Syngenta registrations that support use on cranberries, 

there are several registrations that do support this use (e.g., 19713-273, 19713-60, 72693-7). 

Comment3. 

EPA Statement Page 3, Table 3, 

Formulation Types(s) 

" .. Simazine is formulated either as a liquid, emulsifiable concentrate .... " 

Syngenta Comment: 

Syngenta respectfully requests to delete emulsifiable concentrate as a type of formulation. 

BEAD Response: Refer to BEAD's response in Section I, Comment 2. 

References: 

EPA 2012, Pesticides: Registration Review. Internet Publication: 

http://www .epa.gov /oppsrrd 1/registration _review/ 

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